The recent decision to allow rear facing cameras with in cab monitors to replace rearview mirrors creates an added procedure to the NASTI procedures so roadside officers can inspect and identify potential safety issues. Rearview mirrors are an imperative in vehicle safety and in my opinion a long over looked safety device not addressed in the OOS Criteria.

The trucking industry is seeing more ill trained drivers damaging equipment, property and traffic snarls as they use routes not designed for CMVs. In my opinion roadside officers should place vehicles OOS if the rearview mirrors are damaged.

Astonishingly Part 393.80 rear view mirrors are not part of the SMS calculation! https://ai.fmcsa.dot.gov/SMS/Event/Inspection/51888313.aspx

Rearview mirrors are crucial in drivers' ability to see traffic around the vehicle and avoid accidents. How cannot such an important safety device not be included in SMS or the OOS criteria? The added technology will not be impervious to malfunctions and as such must be checked when ever it is encountered as the support network for the device will be sparse creating a need for the vehicle to travel long distances to be inspected and repaired creating a significant safety issue in route as the driver will not be able to check the area next to the vehicle for lane changes and passing.

Rearview mirrors are a key safety device and are crucial for a driver to identify other vehicles traveling alongside the CMV. It is time for SMS and the OOS criteria to recognize this crucial safety device to avoid lane change and passing accidents. I realize that rearview mirror violations rarely occurs; however, anytime it's discovered that rearview mirrors are missing the CMV should be placed OOS to ensure the public's and driver's safety.

Have Part 393.80 be added to the OOS criteria to include the recent rear facing cameras to be used as rearview mirrors and add Part 383.80 to SMS as a violation that impacts SMS scores.

Vehicle Committee indicated that SMS is not something that CVSA can deal with. They also indicated that without crash data it is very difficult to determine whether a violation of a mirror should be considered for inclusion into the OOSC.

The issue was transferred to the Crash Data and Investigative Standards Committee to see if they could obtain and crash data and make a determination if it justifies an OOSC update.

The crash committee directed staff to examine whether states collected post-crash mirror data, other than in a narrative, for contributing factors in crashes. Staff researched the issue working with NTSB and determined there were no viable data sets collected by states on mirror use or mirrors as a contributing factor in crashes.